On Point blog, page 1 of 60
COA finds evidence supports TPR dispositional order and affirms
Marquette Department of Human Services v. B.L.J., 2026AP400-402, 5/7/26, District IV (ineligible for publication); case activity
In yet another decision applying the deferential standard of review to a TPR dispositional order, COA rejects the appellant’s arguments which ignore that standard of review.
COA rejects challenges to TPR dispositional order
Brown County Health &Human Services v. J.L., 2026AP176, 5/1/26, District III (ineligible for publication); case activity
“Julie” challenges the circuit court’s exercise of discretion at disposition as to two factors of consideration. However, the deferential standard of review applicable to dispositional decisions results in affirmance.
COA rejects multiple challenges to TPR and affirms
Monroe County Department of Human Services v. A.S., 2026AP65-66, 4/23/26, District I (ineligible for publication); case activity
Although A.S. raises multiple challenges to this TPR, COA uniformly finds her arguments unavailing.
Defense win: COA affirms circuit court order for plea withdrawal in yet another TPR burden of proof appeal
State v. D.H., 2025AP2668, 4/10/26, District I (ineligible for publication); case activity
Potentially reviving an issue many may have thought already settled, COA upholds the circuit court’s order for plea withdrawal in a case involving a deficient colloquy regarding the dispositional burden of proof in a TPR case.
COA rejects attempt to apply Cronic to TPR IAC claim and affirms
State v. V.T., 2025AP1338-40, 3/23/26, District I (ineligible for publication); case activity
In an interesting ineffectiveness appeal, COA confronts clear-cut deficient performance but declines V.T.’s invitation to depart from the Strickland prejudice standard.
COA: Although plea in TPR appears “questionable,” parent did not prove manifest injustice meriting plea withdrawal
State v. B.A.J., 2025AP1476-77, 4/2/26, District I (ineligible for publication); case activity
In a case that demonstrates the high burden that parents must satisfy to withdraw their pleas, COA affirms despite also acknowledging the “questionable” nature of this mentally ill parent’s plea.
Defense Wins: COA reverses summary judgment at grounds phase of TPR proceeding.
Sawyer County Health & Human Services v. D.K., 2025AP2832, 3/12/26, District III (ineligible for publication); case activity
The COA reversed the order terminating “Daniel’s” parental rights after summary judgment was granted at the grounds phase because genuine issues of material fact exist whether the County made reasonable efforts to provide services.
COA rejects challenges to TPR dispositional order and affirms
Jefferson County DHS v. G.J.J., 2025AP2491, 3/5/26, District IV (ineligible for publication); case activity
While G.J.J. gets closer than most–and his arguments even give COA “pause”–ultimately, the deferential standard of review applicable to dispositional decisions results in affirmance.
Defense win: COA upholds jury’s verdict in favor of TPR respondent
J.R.P. v. W.P.M., 2024AP1535, 2/19/26, District IV (ineligible for publication); case activity
In a rare sufficiency challenge pursued by the petitioner, COA applies a deferential standard of review and affirms.
COA rejects challenge to TPR dispositional order and affirms
State v. L.Z., 2025AP2731-32, 2/17/26, District I (ineligible for publication); case activity
Although L.Z. tries to capitalize on certain statements in the court’s oral ruling as giving a foothold for her appellate challenge, the standard of review means the argument attacking a discretionary decision goes nowhere.